“Law enforcement need not obtain a warrant prior to conducting a protective vehicle search, so long as there is reasonable suspicion a suspect is dangerous and may gain immediate control of weapons. We are confronted with whether a suspect’s potential access to firearms alone satisfies these prerequisites. Under the circumstances presented here, involving a recreational sportsman cited for a fishing violation, we hold it does not. We thus affirm the superior court’s order of suppression.” State v. Cruz, 2016 Wash. App. LEXIS 1665 (July 19, 2016).

Defendant was under a broad probation search condition, and this search was based on reasonable suspicion and valid. United States v. Rodriquez, 2016 U.S. App. LEXIS 13143 (8th Cir. July 19, 2016).*

Two stops of defendant towing a van a couple of minutes apart were separately justified. The second stop was based on the owner of the van saying that defendant took it from him, but that was only to a second officer on the scene, not the one who stopped defendant. After defendant pulled away, the second stop occurred, and it was based on new facts. State v. Monafo, 2016 N.M. App. LEXIS 50 (July 5, 2016), different result on rehearing 2016 N.M. App. LEXIS 75 (July 28, 2016) and reposted Sept. 17, 2016 with new issue.

Defendant was on probation and he visited his cousin on probation. His cousin’s PO showed up and was going to conduct a probation search of the premises. Defendant was told he wasn’t under arrest and that he was being handcuffed only for officer safety and he’d be shortly released. Defendant’s admissions were noncustodial. State v. Barnes, 2016 N.C. App. LEXIS 771 (July 19, 2016).*